Toxics Use Reduction Institute Policy Analysis October 2017 C1-C4
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Toxics Use Reduction Institute Policy Analysis October 2017 C1-C4 Halogenated Hydrocarbons/Halocarbons Not Otherwise Listed (C1-C4 NOL) This document analyzes the implications of adding a category, C1-C4 Halogenated Hydrocarbons/Halocarbons Not Otherwise Listed (C1-C4 NOL), to the TURA list of Toxic or Hazardous Substances (TURA List). With this addition, businesses in TURA covered sectors with 10 or more full time employee equivalents (FTEs) would be subject to TURA program requirements if they manufacture or process 25,000 lb/year, or otherwise use 10,000 lb/year, of chemicals in this category. These businesses would be required to file annual toxics use reports, pay annual toxics use fees, and develop a toxics use reduction plan every two years. This policy analysis explains the definition of the proposed category, summarizes key scientific information, reviews existing information about how the chemicals in this category are used, discusses opportunities for toxics use reduction, summarizes relevant regulatory information, and discusses the implications of this policy measure for the TURA program. The TURA Science Advisory Board (SAB) has recommended adding this category to the list. Based on all this information, the Toxics Use Reduction Institute recommends that this category be added to the TURA list. 1. Category Overview This document discusses a proposed new category referred to as C1-C4 Halogenated Hydrocarbons/Halocarbons Not Otherwise Listed (C1-C4 NOL). This category is defined as chemicals with 4 or fewer carbons, at least one halogen1, and only hydrogen as the other constituent, that are not already individually listed on the TURA chemical list. This includes fully halogenated chemicals that contain no hydrogen. Development of this category resulted originally from discussions surrounding the addition of n- propyl bromide (nPB) to the TURA list in 2009. During the Science Advisory Board (SAB) discussion of nPB, it was noted that regrettable substitutions can occur readily; small changes to chemicals currently on the market can result in the introduction of other, similarly toxic chemicals that are not regulated. The SAB has now evaluated a range of similar chemicals, in order to support an effort to avoid regrettable substitutions. Some chemicals that meet the criteria for this category are theoretical; that is, they are not currently manufactured or used, but are expected to pose health and environmental concerns if they were to be manufactured and used. 1 Universe of chemicals. As shown in Appendix 1, the chemicals in this category would include halogenated unbranched alkanes with 1 to 4 carbons, halogenated branched alkanes with 4 carbons, halogenated cyclic alkanes with 3 or 4 carbons, halogenated alkenes with 2 to 4 carbons, and potentially halogenated alkynes (this last is theoretically possible, but not commercially available). The TURA program has created a working list of over three hundred possible chemicals that would be part of this category. However, only a fraction of those chemicals are in commerce in the US, and many fewer are expected to be used in reportable quantities in Massachusetts. Thus, while the number of chemicals in the proposed category is large, the number of filers is expected to be low. Relationship to chemicals already listed under TURA. The chemical structures, health effects, and use profiles of chemicals in the proposed category are similar to those of certain chemicals that are already listed. For context, it may be helpful to understand that a number of chemicals already identified as Higher Hazard Substances (HHS) under TURA meet the chemical structure criteria for this category. These include trichloroethylene (TCE), perchloroethylene (PCE or “perc”), and 1-bromopropane (n-propyl bromide, or nPB). Other chemicals that meet this description and are already listed under TURA, but not designated as HHS, include chloroform, 1,2-trans dichloroethylene and Freon 113. Reporting on these and other listed chemicals would not change with the addition of this category; the category would cover only those chemicals that are not already listed individually. 2. State of the science Based on the SAB’s review, central nervous system (CNS) effects are found consistently across the chemicals in this proposed category. Additional hazards noted for some of these chemicals include target organ toxicity; reproductive and developmental toxicity; carcinogenicity; and respiratory effects. In addition, most are persistent in air and/or sediment and many are ozone depleting chemicals and/or are greenhouse gases. SAB approach. Initially, TURI created a list of 136 chemicals meeting the chemical structure criteria for inclusion in the group. This list included some chemicals already on the TURA list in order to compare toxic effects. For this group, TURI collected a standard set of environmental health and safety (EH&S) data. The data set includes PBT information, human health information such as carcinogenicity, neurotoxicity and reproductive toxicity, and physical properties information such as vapor pressure, among other data points. The SAB also chose four sample chemicals – two pairs of chlorinated and brominated analogs -- for a review in greater depth: acetylene tetrachloride, acetylene tetrabromide, 1-bromopropane, and 1-chloropropane. Of 2 these four, 1-bromopropane is listed on the TURA list and was useful for comparison since the SAB had recently reviewed it for listing. Health effects. The SAB found that there were data indicating neurotoxicity for 57 of the 136 chemicals. For the remaining chemicals on this list, no studies on neurotoxicity were found in the National Library of Medicine’s HazMap database.2 In California’s Proposition 65 list, twenty-six of the chemicals on the list are listed as carcinogens, and 5 are listed as reproductive/ developmental toxicants. Additional hazards noted for some of these chemicals include target organ toxicity (cardiovascular, liver, kidney, gastrointestinal, blood), and respiratory effects. Environmental Effects. Environmental concerns include persistence in air and/or sediment, ozone depletion, and global warming potential. Most of the chemicals exhibited persistence and/or toxicity to aquatic organisms. Results from EPA’s PBT profiler indicate that, of the 136 chemicals, 109 are persistent in air, 42 are persistent in sediment, and 81 are very persistent in sediment. Sixty-nine pose moderate chronic toxicity to fish, and 15 pose high chronic toxicity to fish. Physical properties. At room temperature, 57 of the 136 chemicals are liquids; 24 are gases; 3 are solids; and the remainder are not characterized. Twenty-six of the chemicals are flammable liquids or gases. The SAB observed that in general, the chlorinated chemicals in the category have higher volatility than the brominated chemicals. TURI review of additional chemicals. After the SAB’s review of the data on the initial list of 136 chemicals, TURI obtained a more comprehensive list of refrigerants, and noted which of these refrigerants are in the C1-C4 NOL category and may be in commerce according to the TSCA Inventory. For those that had not already been reviewed by the SAB, TURI checked neurotoxicity data. TURI verified that nearly all have evidence of neurotoxicity, consistent with the findings of the SAB for the chemicals they had reviewed. 3. Use information The chemicals in this proposed category may be used as solvents, propellants, refrigerants, blowing agents, fire extinguishing agents, chemical intermediates, and a variety of other uses. Many of the chemicals in this category can be used for multiple uses. For example, a sample chemical in this category, trifluoromethane, is used as a fire suppressant and as a refrigerant, as well as a variety of other uses including as an electronic gas and in solvent cleaning.3 Massachusetts data available from Tier II. Tier II requires reporting of any chemical with an SDS if it is stored at 10,000 pounds or more at a facility (the threshold is 500 pounds for 3 extremely hazardous substances). A review of the 2015 Tier II data shows approximately 76 records for chemicals in this proposed category stored at Massachusetts facilities. The majority of these records are for refrigerants, and fewer refer to solvents. As shown in Table 1, 9 chemicals in the proposed C1-C4 NOL category were reported under Tier II in Massachusetts in 2015. Most are reported by only a handful of facilities, while others appear to be used more widely. The most commonly reported chemical in the category is 1,1,1,2- Tetrafluoroethane (R134a). TURI reviewed the Tier II data for those chemicals meeting the chemical criteria and not already listed under TURA. To develop an expected number of TURA filers, TURI limited the data set based on reportable SIC codes, employee numbers, and quantity of chemical reported. Based on this analysis, the number of facilities that are likely to report on the category based upon Tier II is approximately 14. Table 1: 2015 Tier II data Chemical name Tier II reports Expected number of TURA filers 1,1,1-Trifluoroethane [HFC- 1 1 143a] 1,1,1,2-Tetrafluoroethane 21 5 [R134a]* 1,1-difluoroethane [HFC-152a] 1 1 Fluoroform [HFC-23] 2 0 Pentafluoroethane 1 1 Refrigerant (NOS**) 35 3 R-410 2 0 Solvent (NOS**) 10 3 Tetrafluoromethane [PFC-14] 3 0 Total 76 14 This table shows Tier II reports for chemicals that meet the chemical structure criteria for the C1-C4 NOL category and are not already reportable individually under TURA. To develop an expected number of TURA filers, TURI limited the Tier II data set based on TURA reportable SIC codes, employee numbers, and quantity of chemical reported. *Banned in the EU for use in specified automotive air conditioning systems.4 ** Not otherwise specified It is worth noting that there could be facilities that would be subject to TURA reporting requirements that may not appear under Tier II, either due to reporting errors or due to threshold considerations. For example, when n-propyl bromide (nPB) was added to the TURA list, there were no facilities filing under Tier II, but three facilities subsequently filed under TURA.